1.     S T A N D A R D S A N D   R U L E S

Compliance With The Law

Employees must comply with applicable laws

Sneha Advisory Services and its every employees should comply in good faith with all applicable laws and external regulations, in every jurisdiction where Sneha Advisory Services engages in any activity.

All employees have a duty to familiarize themselves with any applicable laws and external regulations that apply to their country and/or business. Due to the global nature of the business of Sneha Advisory Services, inappropriate conduct in one country can have an effect and potentially lead to issues in other countries too. If employees feel that this might be the case, they can contact their local management, Group Legal or Group Compliance for guidance.

Compliance With Policies, Directives, Guidelines And Handbooks

Employees must comply with all Sneha Advisory Services policies, directives, guidelines and handbooks

Employees are expected to comply with all current and future, policies, directives, guidelines, handbooks and other internal regulations distributed by Sneha Advisory Services. Sneha Advisory Services will make all such policies, directives, guidelines, handbooks and other internal regulations available to employees either directly through local management or by publication on company sources such as Sneha Advisory Services’s intranet.

In addition, all employees have a duty to familiarize themselves and comply with the guiding principles set out in this Code of Conduct.

Financial Integrity, Accurate Records And Reporting

All employees are responsible, in their respective functions, for financial

integrity and accurate records and reporting

Every Sneha Advisory Services company and its employees should ensure to act with financial integrity in all circumstances, for example when dealing with debts, taxes, expenses etc.

Sneha Advisory Services company and its every employees should comply in good faith with all local and international accounting principles that apply to their business. These principles need to be taken into account when preparing financial statements whether for Sneha Advisory Services itself or when providing financial administrative services to our clients. This requires full, fair, accurate, timely and understandable disclosure.

This also applies to any bookkeeping/accounting services provided to our clients.

All the books and records of companies within Sneha Advisory Services should reflect transactions in conformity with all applicable local and international accounting principles.

Misrepresentation, false statements, forgery, backdating or other deliberate acts resulting in inaccurate records or financials are not permitted and will not be tolerated.

Working Environment within Sneha Advisory Services

Employees must treat each other fairly and with respect

Sneha Advisory Services work environment should be experienced as professional, safe and equal, based on mutual respect. This means that: employees must conduct themselves towards others with fairness, respect, honesty, integrity and professionalism, unlawful discrimination is forbidden, any ethnic, racial, religious, sexual or other type of harassment or abuse is not tolerated and will be sanctioned, equal opportunity is provided for all in recruiting, hiring, promoting, training opportunities, and personnel records and files are always treated with respect and confidentiality. Employee information will only be collected, used and disclosed on a need-to-know basis in accordance with applicable laws and regulations, Sneha Advisory Services’s Privacy Policy and Sneha Advisory Services’s Controller Binding Corporate Rules (BCRs) for International Data Transfers.

BRIBERY AND CORRUPTION

Sneha Advisory Services will not  tolerate bribery and corruption

• Giving bribes

Sneha Advisory Services will not tolerate any form of offering, promising or giving of any financial or other advantage: to another person or company, wherever they are situated and whether they are a public official or body or private person or company, by any employee, agent or other person or body acting on Sneha Advisory Services’s behalf, in order to induce or reward the other person or body for improperly performing a relevant function or activity.

• Receiving Bribes

Sneha Advisory Services will not tolerate any form of requesting, agreeing to or accepting of any financial or other advantage:

from another person or company, wherever they are located and whether they are a public official or body or private person or company, by any employee, agent or other person or body acting on Sneha Advisory Services’s behalf, in order to be induced or rewarded for improperly performing a relevant function, role or activity which is part of that person’s function, role or activity at Sneha Advisory Services.

• Bribery of Public Officials

In addition to the above, Sneha Advisory Services specifically will not tolerate direct or indirect bribery of public officials or bodies: by any employee, agent or other person or body acting on Sneha Advisory Services’s behalf, in order to gain influence for the purpose of obtaining or retaining business, or any other advantage in business for Sneha Advisory Services and/or its clients.

This includes but is not limited to offering money to public officials in order to speed up service or gain improper advantage (facilitation payments or grease payments), regardless whether such payments are considered ordinary practice and are not prohibited in some countries. If in doubt contact Sneha Advisory Services Legal or Group Compliance.

• Entertainment and Gifts

Gifts and entertainment should never influence an employee’s business decision or cause others to perceive an influence.

Offering and receiving gifts can be lawful and considered legitimate to strengthen client relationships. However, within Sneha Advisory Services, employees are not allowed to provide or receive gifts or corporate hospitality, internally or externally: in the form of cash or cash equivalents.

Insider Trading

Insider trading and information tipping are strictly forbidden. Insider information is defined as: information regarding any publicly traded company obtained by employees in the course of their duties for Sneha Advisory Services where, such information may be considered to have material value to any ‘sensible’ investor in the decision to carry out securities transactions, and such information is not (yet) available to the general public.

Sneha Advisory Services expressly prohibits any form of exploitation of insider information. More concrete, the employee should in any event avoid:

• buying, selling or otherwise trading shares or other securities while being in possession of insider information,
• disclosing insider information about a company to any other person, including family members, friends or colleagues, where that information may be used by the other person to trade in the company’s securities, recommending or suggesting that anyone else buys, sells, retains or otherwise trades in shares or other securities of any company while having insider information about the company, and/or providing access to insider information when it does not meet the strict need-to-know requirement.

In order to prevent any perception of possible insider trading from arising, an employee should avoid investing, shareholding or partnering in the business of a client which the employee is in anyway involved with or has knowledge about through the employee’s position within Sneha Advisory Services, unless through a fiduciary account arrangement. The employee shall also refrain from giving any specific instructions or otherwise influencing any decision to be taken under this fiduciary account arrangement.

At first request of Sneha Advisory Services, an employee shall provide Sneha Advisory Services with all relevant information with regard to the employee’s investments in order for Sneha Advisory Services to monitor compliance with the obligations as set out above.

Note that employees of Sneha Advisory Services in certain roles can be considered an insider in relation to information of a client and additional rules may apply in such situation (for example, additional rules of the client).

Fighting Corrupt Practices

Employees shall not engage in money laundering or other corrupt practices and report unusual transactions

The term ‘money laundering’ refers to the process whereby individuals or entities try to conceal funds raised from illegal activity or make these funds look legitimate. Sneha Advisory Services will not tolerate, facilitate or in any way support money laundering activities.

Every employee must adhere to the following principles:

• All clients of Sneha Advisory Services must undergo a thorough Know Your Client (KYC) check through Group Compliance. No client may be contracted or served without explicit consent of Group Compliance in accordance with the relevant Sneha Advisory Services internal compliance policies,

Sneha Advisory Services is obliged to establish its client’s identity, the client’s beneficial ownership and/or to determine the origin of clients’ funds. If, at some subsequent stage in the relationship with the client, changes occur or doubts arise as to the correctness of the facts as initially stated by the client, the appropriate inquiries must be repeated and reported to local management. If necessary local management can inform Group Compliance and/or Group Legal,

Transactions which are unusual for a given client or in which the underlying economic circumstances are unclear must be examined in order to ascertain whether they should be characterized as an unusual or even unlawful transaction which are to be reported to local management, local compliance or Group Compliance. If necessary local management can inform Group Compliance and/or Group Legal and/or notified to the relevant authority (suspicious activity reporting),

employees may not participate or provide any assistance to clients or otherwise to deceive any authorities such as tax authorities, for example by giving incomplete or misleading statements, and

the presence of employees at discussions between clients and third parties or the holding of discussions on Sneha Advisory Services premises could be (mis)construed as an indication that Sneha Advisory Services is in agreement with or even supports the actions of a certain party. Employees should distance themselves clearly and at an early stage, if they suspect or become aware that the matters discussed may give rise to corrupt practices and report this to local management as an incident.

Avoidance of conflict of interest Conflict of interest must be avoided and in any event disclosed

Employees must avoid situations which give rise or may give rise to a conflict of interest between an employee and Sneha Advisory Services, Sneha Advisory Services and a client/third party or an employee and a client. In addition, the mere perception of a conflict of interest must be avoided.

Sneha Advisory Services values the avoidance of a real conflict of interest as much as the avoidance of the mere perception of conflicts of interest. Perception can be just as damaging to Sneha Advisory Services’s reputation and that of the employee as any real conflict.

An employee faces a conflict of interest when the employee’s personal relationships, interest in another venture or participation in external activities influences or could be perceived to influence the employee’s decisions.

hold a direct or indirect financial interest in any business or organization of a client or competitor of Sneha Advisory Services, when the employee has the ability to influence the decision with respect to Sneha Advisory Services’s business (e.g. the client or competitor is owned, managed or controlled by a family member or close friend), and/or

• have an outside business or other interests which interfere with the ability of the employee to perform the employee’s duties for Sneha Advisory Services.
• Any work-related conduct that brings the employees, their family members or close friends any unauthorized personal benefit that would harm Sneha Advisory Services or any of its stakeholders is prohibited.

Employees should realise that conflict of interests could arise when acting as director or in another fiduciary role for clients in general and especially when Sneha Advisory Services also provides additional services, for example bookkeeping, to the client. If this is the case, please act in accordance with the relevant provisions in local law or articles of association. In any event disclose the conflict to the client.

If you think you may face a conflict of interest or that others could perceive an activity or relationship you are engaged in as conflict of interest, you must promptly disclose this to local management. Familial relationships with government officials should in any event be reported, to assess whether or not any mitigation steps are required in order to protect the employee, the employee’s family member or Sneha Advisory Services. If necessary, local management will inform Group Legal or Group Compliance.

CONFIDENTIALITY

Information should be protected from undue disclosure and may only be accessed by authorised employees

All employees must observe the strictest confidentiality concerning all confidential information whether relating to Sneha Advisory Services itself or to client relationships, which come to their attention during the course of their activities performed for Sneha Advisory Services. Sneha Advisory Services recognizes various levels of confidentiality, including Public, Internal, Confidential, Restricted. These classifications are further described and defined in Sneha Advisory Services’s Data Classification Policy.

Such confidential information includes all non-public information that is or may be harmful to Sneha Advisory Services or its clients if disclosed, including business information that might benefit a competitor.

When in doubt on whether information is confidential, employees should consider information Restricted for internal information purposes and Confidential for client information purposes.

Even the mere fact that a client relationship with Sneha Advisory Services exists should in principle be confidential, unless already public information or disclosure is permitted by the client.

Clean desks and clean screens are an important element in maintaining confidentiality.

Employees must ensure that all confidential information is locked away when not in use. Computer access must be blocked when left unattended by shutting down or locking the computer.

Information must solely be used for the purpose of exercising the employee’s responsibilities on behalf of Sneha Advisory Services. When dealing with classified information, any specific rules that apply must be observed at all times. Information classified as Confidential or Restricted may only be passed on to other employees or taken off Sneha Advisory Services premises with written permission of the information owner or managing director.

Furthermore, any special regulations governing the safekeeping, storage and destruction of documents and data must be observed.

The obligation to safeguard confidential information continues after termination of employment with Sneha Advisory Services. When employees leave the service of Sneha Advisory Services they must surrender all information which came into their possession in the course of the employment relationship and which are either the property of Sneha Advisory Services or its clients.

Protection of and Access to Information

Employees shall adhere to all measures taken by Sneha Advisory Services to protect its information

Employees are given personal access credentials. Personal access credentials include at least a user-ID and password and may include additional credentials such as an access badge, token and smartcards. These credentials may not be shared with others, including colleagues, friends and family. Employees are assigned access rights based on requirements associated with their roles in the organization.

All non-personal information must be accessible by a superior and anyone requiring access to the information in line with their job responsibilities. Employees are strongly encouraged to set a proxy access to their email box for their backup and their direct superior. Automatic forwarding of business email to a non-business email address is not allowed. Manual forwarding of emails to the employee’s non-business email address is only allowed if approved by local management. Access to email on remote or mobile devices is only permitted if the device on which the email is to be received is configured by Sneha Advisory Services IT in accordance with the security policies.

Internet may only be accessed through Sneha Advisory Services approved secure configurations when accessing via Sneha Advisory Services’s network or on Sneha Advisory Services IT assets. Employees are not permitted to circumvent these secure configurations, even if technically feasible.

Sneha Advisory Services assets must be used with care and responsibly

Sneha Advisory Services assets can be physical or intangible. It may include buildings, equipment, software, data, know how, designs, logo, trade names and trade secrets.

All Sneha Advisory Services’s assets should be protected from misuse, theft, loss, damage or infringement. Any use of these assets other than for Sneha Advisory Services’s business (e.g. personal use, community or charitable endeavours) should be avoided and requires the express authorisation by local management.

The use of Sneha Advisory Services’s assets for personal gain or illegal purposes is prohibited.

Employees must always use the correct headed paper, forms, brochures, etc. Headed paper and forms, bearing the logo of Sneha Advisory Services or one if its subsidiaries, are to be used solely for business purposes and may not be handed out blank to clients or third parties.

Events and presentations in the name of Sneha Advisory Services and the use of its logo are permitted only for business purposes. Group Marketing and Communications should be involved in the use of the logo or other marketing material.

Employees must only use Sneha Advisory Services owned or controlled IT assets and may not modify the assets (e.g. by installing software) without consent or assistance of Sneha Advisory Services Technology. Copying or distribution of licenses owned or assigned to Sneha Advisory Services is only allowed with written consent of Sneha Advisory Services Technology.

Any information that is unclassified or classified other than Public and needs to be stored on an IT asset must be secured according to security specifications described in Sneha Advisory Services’s Information Security Policy. Theft or loss (including prolonged misplacements) of devices that potentially contain Sneha Advisory Services owned or managed information must be reported promptly to Sneha Advisory Services Technology.

INTELLECTUAL PROPERTY

Intellectual property rights developed in the working environment of Sneha Advisory Services belongs to Sneha Advisory Services. Third party intellectual property rights should not be kowingly infringed

All intellectual property rights developed at any time during working hours, in the normal course of their duties or with Sneha Advisory Services’s materials and/or facilities which relate to the business of Sneha Advisory Services belong to Sneha Advisory Services. Sneha Advisory Services does not owe the employee any compensation in that respect.

Third party intellectual property rights should not be knowingly infringed.

Complaints

Complaints should be taken seriously and reported to local management

Complaints must always be taken seriously and dealt with immediately. They represent an opportunity to strengthen client relations and to remove the sources of client dissatisfaction. Complaints must be dealt with efficiently and in a friendly and accommodating manner.

Employees are required to report all complaints received from clients to local management immediately and handle in accordance with the Complaint Handling Procedure. Local management should take such appropriate action as they deem necessary to avoid similar complaints in the future. Local management reports any standing complaints in their monthly reporting to the Executive Committee.

Local Sneha Advisory Services offices may be subject to more stringent local laws or complaint policies in place, adherence to which is of course required.

C O M P L I A N C E   W I T H   C O D E   O F  C O N D U C T

Sneha Advisory Services and all its employees are bound to follow the standards as set out in this Code of Conduct. Agreement to comply with this Code of Conduct is a condition of employment within Sneha Advisory Services. All employees must familiarize themselves with the content. All employees are expected to sign an acknowledgement to confirm that they have read, understood and will abide by this Code of Conduct.

Compliance with the Code of Conduct is the exclusive responsibility of every employee. Employees, once informed of the Code of Conduct, may not plead ignorance or obedience to higher ranking officials.

As far as the nature of each relationship permits, all principles and rules set out in this Code of Conduct shall apply to the relations that Sneha Advisory Services has with subcontractors, agents, consultants, contractors, interns and trainees.

In case of a violation, this may lead to disciplinary sanctions or, in accordance with the seriousness of the violation and with the applicable laws, to dismissal and legal action being initiated even after dismissal. Certain violations can also lead to severe penalties under applicable law or even imprisonment.
Waiver of any provision of this Code of Conduct must be approved by the General Counsel/Head of Group Governance.